Grant Matching Funds helps you to understand what is needed to unlock matching funds, we are specifically focused on BEAD requirements but most information and lessons is applicable for any grant matching funds and/or when you are seeking external capital to fund a project or business.
This section is intended for existing local providers interested in pursuing matching capital for BEAD application. Whether you have definite plans already, or need to explore the possibilities, this module is for you – if you already own and / or operate a provider business in at least one state or territory. This section can be completed directly, or via your consultant (you’ll be able to invite them to your application model).
Understand how In this Module, you’ll learn about the matching rules for BEAD, they types of matching capital available to you, and the tools and questions you’ll need to use to unlock the capital to deliver your project.
The middle mile NOFO defines “middle mile infrastructure” as “any broadband infrastructure that does not connect directly to an end-user location, including an anchor institution; and includes— (i) leased dark fiber, interoffice transport, backhaul, carrier-neutral internet exchange facilities, carrier-neutral submarine cable landing stations, undersea cables, transport connectivity to data centers, special access transport, and other similar services; and (ii) wired or private wireless broadband infrastructure, including microwave capacity, radio tower access, and other services or infrastructure for a private wireless broadband network, such as towers, fiber, and microwave links.”
Except in certain specific circumstances described herein (including projects in designated “high-cost areas” and other cases in which NTIA has waived the matching requirement), each State shall provide, require its applicants to provide matching funds of not less than 25 percent of project costs. Funds from other Federal programs including the FCC generally may not be used as matching funds; however, the
Infrastructure Act expressly provides that matching funds for the BEAD Program may
come from a federal regional commission or authority and from funds that were provided to a State or applicant for the purpose of deploying broadband service under the Families First Coronavirus Response Act; the CARES Act, the Consolidated Appropriations Act, 2021; or the American Rescue Plan Act of 2021, to the extent permitted by those laws.
State should rigorously explore ways to cover a project’s cost with contributions
outside of the BEAD program funding. Matching contributions, including in-kind contributions that lower project costs, demonstrate commitment to a particular project and minimize BEAD funding outlay, extend the reach of the BEAD program funding and help to ensure that every unserved location and underserved location in the United States has access to reliable, affordable, high-speed internet.
In some cases, though, a match requirement could deter participation in the BEAD Program by small and non-traditional providers, in marginalized or low-income communities, or could threaten affordability (i.e., if an applicant seeks to offset the cost of a substantial match through higher end user prices). In those cases, the State should consider ways to cover part or all of the provider’s match through the State or other funds or seek a match waiver through the process explained below. A matching contribution may be provided by the applicant, a State entity, a unit of local government, a utility company, a cooperative, a nonprofit or philanthropic organization, a for profit company, regional planning or governmental organization, a federal regional commission or authority, or any combination thereof.
While the match may be provided by multiple sources, States are encouraged to require a match from the applicant rather than utilizing other sources where it deems the applicant capable of providing matching funds. This approach will maximize the impact of States funds and funds provided via other federal programs. As detailed below with regard to the applicant selection process for last-mile broadband deployment projects,States are also required to incentivize matches of greater than 25 percent from applicants wherever feasible (especially where expected operational costs and revenues are likely to justify greater investment by the applicants) by focusing on minimizing the BEAD funding outlay on a particular project. NTIA will provide technical assistance to States to assist in making these determinations. States will be expected to explain in their Initial Proposals how they intend to ensure that applicants will offer the maximum feasible match for each project.
The Infrastructure Act expressly provides that matching funds for the BEAD Program may come from a federal regional commission or authority and from funds that were provided to a State or an applicant for the purpose of deploying broadband service under the Families First Coronavirus Response Act, the CARES Act, the Consolidated Appropriations Act, 2021 or the American Rescue Plan Act of 2021, to the extent permitted by those laws.
States are encouraged to consider terms and conditions that may be associated with potential sources of match funds and how those may impact the project overall. For example, if a State utilizes federal regional commission funding as a match, the project will need to comply with all BEAD programmatic requirements and any requirements imposed by the federal regional commission.
Likewise, States that use funds from the Coronavirus State and Local Fiscal Recovery
Funds or Coronavirus Capital Projects Fund as the source of matching funds for the BEAD Program must comply with the requirements of both the BEAD Program and the relevant Treasury program. Loan funding issued through a federal agency, such as through the USDA ReConnect Program, may also be used as match funding.
Matching funds may be provided in the form of either cash or in-kind contributions, so long as such contributions are made consistent with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. In-kind contributions, which may include third-party in-kind contributions, are non-cash donations of property, goods or services, which benefit a federally assisted project, and which may count toward satisfying the non-federal matching requirement of a project’s total budgeted costs when such contributions meet certain criteria.
In-kind contributions must be allowable and allocable project expenses. The rules governing allowable in-kind contributions are detailed and encompass a wide range of properties and services. NTIA encourages applicants to thoroughly consider potential sources of in-kind contributions that, depending on the particular property or service and the applicable federal cost principles, could include employee or volunteer services; equipment; supplies; indirect costs; computer hardware and software; and use of facilities. In the broadband context this could include, consistent with federal cost principles, waiver of fees associated with access to rights of way, pole attachments, conduits, easements, or access to other types of infrastructure.
In evaluating requests for waiver of the BEAD Program’s non-federal match requirement, NTIA will carefully balance the Program’s various objectives. It is NTIA’s policy to ensure that BEAD funds are used to bring affordable broadband to all Americans. Thus, the Assistant Secretary will generally seek to minimize the BEAD funding outlay on a particular project to extend the Program’s reach, and expects to grant waivers only in special circumstances, when waiver is necessary to advance objectives that are critical to the Program’s success. In order to be considered for a waiver, a State must submit a request that describes the special circumstances underlying the request and explain how a waiver would serve the public interest and effectuate the purposes of the BEAD Program. The Assistant Secretary retains the discretion to waive any amount of the match, including up to the full 25 percent requirement.
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